Motion to Temporarily Seal Supplemental Response

CASE CLRK

BY AUG

ND OF 30

OM.

CR29-22-2805 DIST 2023

LATAH COUNTY PROSECUTOR'S OFFICE CT

WILLIAM W. THOMPSON, JR., ISB No, 2613 DEPUTY PM1 .

PROSECUTING ATTORNEY LATAH:

11 ASHLEY S. JENNINGS, ISB No. 8491
SENIOR DEPUTY PROSECUTOR

Latah County Courthouse P.O. Box 8068 Moscow, ID 83843
Phone: (208) 883-2246 ISB No. 2613 paservice@latahcountyid.gov
IN THE DISTRICT COURT OF THE SECOND JUDICIAL DISTRICT OF THE
STATE OF IDAHO, IN AND FOR THE COUNTY OF LATAH

STATE OF IDAHO, Case No. CR29-22-2805 Plaintiff,
MOTION TO TEMPORARILY

SEAL STATE'S

SUPPLEMENTAL RESPONSE

TO DEFENDANT'S THIRD

MOTION TO COMPEL

DISCOVERY PENDING

HEARING

V.

BRYAN CHRISTOPHER KOHBERGER,

Defendant.

COME NOW the State of Idaho, by and through the Latah County Prosecuting Attorney and hereby moves the Court pursuant to Idaho Court Administrative Rule 32 (g) (1) and Idaho Code 74-124 for a Temporary Order Sealing " State's Supplemental Response to
MOTION TO TEMPORARILY SEAL

" STATE'S SUPPLEMENTAL

REPONSE TO DEFENDANT'S

THIRD MOTION TO COMPEL

DISCOVERY "

PENDING HEARING 1

Defendant's Third Motion to Compel Discovery " herein because release or disclosure would:
1. Interfere with enforcement proceedings;
2. Deprive a person of a right to a fair trial or an impartial adjudication;
2. Constitute an unwarranted invasion of personal privacy,
3. Disclose the identity of a confidential source; and / or
4. Disclose investigative techniques and procedures.

The undersigned seek this protection pending a hearing on the matter.

Wherefore, the State respectfully prays that the Court seal from public disclosure the " State's Supplemental Response to Defendant's Third Motion to Compel Discovery " herein under the provisions of Idaho Court Administrative Rule 32 (g) (1) and Idaho Code 74-124.

RESPECTFULLY SUBMITTED this 30th day of August, 2023.

ashup rings Ashley Jennings Senior Deputy Prosecutor
MOTION TO TEMPORARILY SEAL

" STATE'S SUPPLEMENTAL

REPONSE TO DEFENDANT'S

THIRD MOTION TO COMPEL

DISCOVERY "

PENDING HEARING 2

CERTIFICATE OF DELIVERY

I hereby certify that true and correct copies of the MOTION TO TEMPORARILY
SEAL STATE'S SUPPLEMENTAL RESPONSE TO DEFENDANT'S THIRD MOTION
TO COMPEL DISCOVERY ” PENDING HEARING were served on the following in the manner indicated below:
Anne Taylor Mailed Attorney at Law ☑ E-filed & Served / E-mailed PO Box 9000 Faxed Coeur D Alene, ID 83816-9000 Hand Delivered 30th day of August, 2023.

Dated this
MOTION TO TEMPORARILY SEAL

" STATE'S SUPPLEMENTAL

REPONSE TO DEFENDANT'S

THIRD MOTION TO COMPEL

DISCOVERY "

PENDING HEARING 3